Under what conditions can an investment professional port their performance track record to a new firm under GIPS?
I'm moving from one investment firm to another and managed a composite at my old firm. Can I bring my performance history to the new firm and claim it as the new firm's track record? The GIPS portability provisions seem strict. What are the requirements?
GIPS portability allows a new or acquiring firm to present the performance track record from a prior firm or affiliation, but only under stringent conditions that ensure the historical performance is genuinely representative of the team's current capabilities at the new firm.\n\nPortability Requirements (all must be met):\n\n1. Substantially all the decision-making personnel responsible for the track record must transfer to the new firm\n2. The decision-making process must remain substantially intact and independent at the new firm\n3. The new firm must have documentation supporting the performance and demonstrating the link\n4. The prior performance must be presented as supplemental information for a minimum transitional period (typically one year) before it can be linked to the new firm's composite\n\nWorked Scenario:\n\nPortfolio manager Gavin and his three-person team managed the International Small Cap composite at Alderton Investments for 8 years, generating a strong track record. Gavin moves to Carrington Partners (a GIPS-compliant firm) and wants to bring the track record.\n\nCondition Check:\n\n| Requirement | Status | Compliant? |\n|---|---|---|\n| Decision-makers transferred | Gavin + 2 of 3 analysts moved | Yes (substantially all) |\n| Process intact | Same model, same research framework | Yes |\n| Supporting documentation | Gavin has composite records from Alderton | Must verify completeness |\n| Independence at new firm | Carrington gives Gavin full autonomy | Yes |\n\nWhat Gavin Can Present:\n\n- Year 1 at Carrington: The Alderton track record may be shown as supplemental information, clearly labeled as performance from Alderton Investments. It cannot be linked to Carrington's composite.\n\n- After Year 1: If the composite continues with the same process and personnel, Gavin can link the historical Alderton performance to the Carrington composite. The presentation must disclose when the track record transitioned.\n\nWhen Portability Fails:\n\n- Only Gavin moves (not the team): The track record cannot be ported because the team that generated it is not substantially intact\n- Carrington imposes different risk limits or trading restrictions: The process is no longer substantially the same\n- Alderton refuses to provide documentation: Without supporting records, portability cannot be claimed\n- Gavin managed the strategy but was one of several equal decision-makers: If the other decision-makers did not transfer, portability is questionable\n\nKey Distinctions:\n- Portability applies to composites, not individual portfolio returns\n- The new firm bears the burden of proof for compliance\n- Verification of the prior firm's track record strengthens the portability claim\n- The acquiring firm must disclose the source and dates of ported performance\n\nLearn GIPS portability rules in our CFA Ethics course.
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